Friday, October 20, 2017

Do You Have the Tools You Need for Future EMS?

Changing World of EMS

It doesn’t take a rocket scientist to figure out that we live in a world of constant change.

Like the rest of the world, there is a changing world of EMS and it’s happening very fast. 

Do You Have the Tools You Need for Future EMS?
Advances in healthcare and technology have changed the way we operate in the pre-hospital environment. The EMS of just a few years ago looks drastically different than the EMS of today and by tomorrow a lot more will have changed.

The questions is, do you have the tools you need to dive into the future of EMS?

Technology

Technology is growing at such a fast pace, it’s hard to keep up. All kind of gadgets and widgets open up a whole new world for EMS to track, trace and analyze the things that we do.

In this highly digital age, we can use the power of computing to learn more about what we do in EMS than at any time since modern EMS came to be in the last four decades. When Dr. “Bones” ran that scanner over his patients onboard the Starship Enterprise, those of us old enough to remember marveled in our dreams at what the future of healthcare may hold.

Now we’re seeing some of those very dreams come to be.

We’ve come a long way from the “scoop and run” mentality through Squad 51 and radio phones and “Rampart.” We’re doing the very things that Gage and DeSoto only dreamed of doing and we’re doing it with precision.

So much has happened in just the last ten years, let alone the last forty years that it’s hard to believe that we operated as we did back in the day.

Analytics

Today we can analyze just about every phase of our EMS operations. We can track the EMS scenario from the point of activation and initiation of the call through responses, treatment, trace outcomes and then tie it all together in the office in order to obtain reimbursement and create efficiency.

We know our costs and can plot them in a computer model that takes into account all of the variables that drive our systems. We know our reimbursements and can trace them from the point of submission of the claim through final disposition.

There are digital tools to peer into every phase of the operation, but can your EMS agency afford those tools and do you have the right people breaking down the data?

It takes a sharp eye and a good bundle of software applications to make all of this come together. Without the right human and digital computing components coming together, it’s all just a bunch of numbers, graphs and tables that can do more to confuse than enlighten.

Today’s EMS Manager

Today’s EMS manager must wear many hats. Not that this was never the case, but that same manager must be street savvy and analytical all at the same time. Knowing how to leverage the large amount of data that flows in and out of the machines and over the desktop each and every day is more than half the battle of running a successful EMS system.

The ability to employ and integrate data streams from many different sources will prove to sift out the successful EMS manager from the not-so-successful one.

When to Seek Help…

Assuming that one person or one team can handle all of the tools to be successful can be a big mistake. When is it time to seek help?

While you may be a very talented EMS manager, the complexity of today’s world implies that no one person can know everything about everything. Knowing when to seek help from outside sources is the hallmark of a wise manager.

And there is plenty of help out there.

In our industry, billing outsourcing companies can take the pain and strain off the worry side of financial concerns. Using an outsourced EMS billing solution, insures that not only do you have a partner to help you focus on important revenue data, but also insures total compliance and constant monitoring for proven efficiencies in the revenue cycle. Reports, data, processes and analysis come with a billing outsource solution.

There are consultants and experts all throughout the EMS world that can assist you by providing you with information that will help you grow, maintain and excel for your EMS system.

It’s time to think out of the box. The EMS manager that is complacent and content with the status quo will watch the world of EMS go past at the speed of light and miss the opportunity to catch up.

Friday, October 13, 2017

Transporting SNF Residents: Choosing the Proper Payer

This week the industry experts at Page, Wolfberg and Wirth (www.pwwemslaw.com) posted an excellent article in the EMS Legal Update on EMS1.com regarding how to choose the proper insurance payer when transporting Skilled Nursing Facility residents by ambulance. The information is so important that we decided to share with you in our blog space this week. We hope you take time to read this important information as prepared by PWW staffer Amanda Stark.

To avoid overpayments or submitting false claims, you must have a process in place for identifying the proper payer for each transport

When you transport a Medicare beneficiary, you should always bill Medicare, right? Wrong! There are times when the bill should instead go to the patient, a group health plan, hospice, a hospital or a skilled nursing facility (SNF). The key to compliance and proper billing is evaluating the transport and determining which payer is responsible.

Image courtesy of Medicare.gov
Any time you receive payment from Medicare when you shouldn’t have, such as when another payer should have been billed, it is an overpayment that must be refunded. To avoid overpayments, or worse, accusations of submitting false claims, you must have a process in place for identifying the proper payer for each transport.

Medicare Part A and B


Of particular interest to the Office of Inspector General (OIG) right now is transports that were billed to Medicare Part B, but should have been billed to a skilled nursing facility. The OIG updated its Work Plan in July to add this as an additional ambulance focus area. The OIG will be investigating to determine whether ambulance transports paid for by Medicare Part B were subject to SNF consolidated billing requirements and, therefore, should have been paid for by the SNFs where the transported patients resided.

We are aware of ambulance services and billing companies who have already received requests from the OIG for more information regarding specific transports of SNF residents. In these requests, the OIG is attempting to determine if the EMS agencies and billing companies have a process in place for determining the proper payer for the transport based on whether the patient was in a Part A stay and the reason the patient was transported.

To make sure you are billing the appropriate payer, it is critical to know the rules for billing for transports of SNF residents. Generally speaking, a transport of a SNF resident in a Part A stay, is billable to the SNF, not Medicare Part B [1].

A Part A stay is the first 100 days of a patient’s stay in the SNF, although it may not be 100 consecutive days if the patient was discharged from the SNF or admitted to the hospital. The best way to determine if the patient was in a Part A stay at the time of transport is to ask the SNF during call intake. If the patient was in a Part A stay at the time of transport, then you should send the bill for the transport to the SNF.

SNF Billing Exceptions


Although transports of SNF residents are usually billable to the SNF, there are exceptions. Regardless of if the patient is in a Part A stay at the time of transport, you should always bill Medicare Part B, if coverage criteria is met, when the transport is for:

  • Initial admission to the SNF
  • Final discharge from the SNF
  • Dialysis treatment
  • Admission to another SNF when the patient is not in a Part A stay
  • Hospital outpatient services listed in the Medicare Claims Processing Manual, Chapter 15, Section 30.2.2

Keep in mind, all transports, whether Medicare Part B or the SNF is responsible to pay, must be medically necessary. However, when it’s the SNF’s responsibility to pay, you are not required to obtain a PCS and you can bill for transports to destinations that Medicare Part B does not cover, such as doctors’ offices.

As with transports billable to Medicare Part B, if the transport is not medically necessary, the patient should get the bill for transport. An Advance Beneficiary Notice (ABN) is not required in order to bill the patient in that situation, although it can be helpful to give patients notice that they will be getting a bill.

Now is the time to take a close look at your procedures for determining the proper payer for each transport. If you have received payments from Medicare Part B when a SNF should have been responsible for payment, you should refund the overpayment within 60 days of identification. Correct and improve your processes going forward to make sure you bill the proper payer every time.

References
1. 42 CFR 410.41(e)

Friday, October 6, 2017

Of Revalidations- Part II- Why So Much Personal Information?

Here we go again…

In this second part of our two-part series talking about the revalidation process, we focus on one of the biggest questions we receive here in our billing office…

“Why do I have to provide my personal information?

Let’s dig in and try to understand the why.

Of Revalidations- Part II- Why So Much Personal Information?

Congratulations!

So you say you’ve just been elected to the Board of Directors or you’ve become an Officer or both for your local EMS Agency.

Congratulations!

Now that you’ve become a Board member or you’ve been elected to an office you’ve been requested to provide some very personal information in that role as a key decision-maker for your organization.

As part of the revalidation mandate Medicare and Medicaid providers and suppliers of services, ambulances included, are required to report vital information about your agency. Included in that information is the identifying information for each person who holds a position of leadership- however that is defined for your organization.

So for each person who sits your agency’s board and holds an office as it pertains to EMS is required to provide Medicare and Medicaid with the following information…
  • Legal Name (First, Middle, Last)
  • Home Address (Medicare does not require but most State’s Medicaid programs do)
  • Social Security Number (and not just the last four digits either)
  • Date of Birth
  • State of Birth
  • Country of Birth (if born outside the United State of America)
  • For managers, the date the person took office
  • Position Held within the Organization
  • For-Profits must report ownership and also in some cases for States’ Medicaid family relationship to other owners

Ever heard of identity theft and privacy?

We’ve known of instances where some directors and principal officials flat out refuse to provide so much personal information. They typically ask something like; “Have you ever heard of identity theft and privacy?”

We get it. We’re all hesitant to release such personal information.

Some Directors and Officers balk because they feel that Big Brother is watching them.

Okay…that’s probably accurate. Certainly, everyone is worried about identity theft. We understand.

It’s why, here in our billing office, the persons involved in assisting clients in the revalidation tasks are staff members who have a proven track record of safe handling of personal and private information. Plus, the Medicare Administrative Contractor’s (MACs) or your State’s Medicaid Provider Enrollment/Credentialing Staff have been proven to be extremely discreet as required within their contractual relationship with the Federal Government.

What will Medicare/Medicaid do with my information?

Medicare and Medicaid will do the following with your information…
  1. Verify you are who you say you are
  2. Verify that you were never convicted of some financial crime or deception that cost the Medicare and Medicaid program dollars paid out inappropriately
    • This is accomplished by comparing your personal information against a database called the “Exclusion List.” It is a list of those persons who have defrauded the Medicare and Medicaid programs out of billing of dollars. The intent is for history to not repeat itself and more money is lost to fraud and abuse.
Once you have been vetted, your EMS Agency will be revalidated and your information will be nicely tucked away in a very secure place until your information or your Agency’s profile changes and an update must be made.

And if I don’t provide the information?

Failure to accurately report all persons that are the key decision-makers as part of your administration, be it members of your Board of Directors, elected officials, officers, managers…whatever applies to your situation can ultimately result in suspension or termination of your Medicare or Medicaid billing privileges which would be disastrous to any EMS agency.

It’s vitally important to complete all required information for the revalidation process in a timely fashion!

Friday, September 29, 2017

Medicare Revalidation – What is it and Why do we do it?

“Why do we have to do this?”

Five years ago Medicare suppliers and providers received the wonderful gift called Medicare Revalidation. Since that time, our billing office has been asked the same question over and over.

“Why do we have to do this?”

Well, a simple question begs a not so simple answer…so here goes. We’re going to use this space both this week and next week to help educate all of you about this process.

Medicare Revalidation – What is it and Why do we do it?Oh, and by the way, if you’ve received a revalidation notice…take action now! If you use our billing office connect with us right away- don’t wait. Chances are we’ve already reached out to you to gather the documents and information we need to assist in completing the revalidation application, so please reply because there is a deadline and it’s not negotiable.

PECOS

One of the reasons for the Medicare revalidation process is to insure that all health care providers (individuals and groups) are registered in the master database called PECOS (Provider Enrollment Chain and Ownership System.) Many years ago, each Medicare “carrier” as they were called back when, maintained a separate database of providers and there was little ability for cross-checking and verification of information across those carrier lines.

Today, carriers are Medicare Administrative Contractors (MAC) and each MAC is partitioned into Jurisdictions or geographic chunks of States where they act on behalf of CMS to administer the Medicare program. These MACs, however, all use PECOS to interconnect and share information across the Medicare system. Now, information about a provider or supplier who once billed Medicare in New York City can be instantly compared with the same provider info should that provider move operations to Los Angeles. This especially comes in handy if CMS is trying to identify individuals or group practices (such as ambulance services and owners/administrators of those ambulances) who may have committed fraud and abuse in one area and now is trying to re-apply under assumed names/aliases, etc. to bill fraudulently again but only in a new geographic location.

The revalidation process will once and for all require all providers to be entered and registered into the PECOS system.

Combating Fraud and Abuse using On-Site Inspections

The revalidation process insures that all provider address locations be verified as legitimate practice locations. This is the reason why CMS and the MAC’s are so picky about the physical office/station/practice addresses complete with a Zip +4 designator in order that a site inspector can visit each location to complete the revalidation verification process.

This step insures that there are no bogus store-front operations set up as cover-ups where real services are not provided. Too many illegitimate health care providers can set up shop in some strange non-active location with money flowing to a remote Post Office Box. Prior to this process, a new ambulance company group provider could have potentially set-up a store-front, strip mall address and report claims billed fraudulently using ambulance vehicles that were sitting in some junk yard somewhere and for services never provided.

As entitlement programs such as Medicare edge nearer to feared insolvency, this is one method that that Congress and CMS has come up with to verify the identity of provider, groups and their owners and administrators prior to paying any further or initial claims.

Is it time…?

Is it time to revalidate?

Our billing office monitors the CMS revalidation site on a weekly basis to insure that we do not miss a revalidation deadline. Additionally, the MACs send out communication letters reminding you of your organization’s revalidation date. The date is also anchored to exactly every five years. Once you have completed revalidation for your EMS agency you will only be required to report changes, but a full revalidation is not necessary in between the fire-year timeframe.

But, be sure to NOT miss the deadline.

Missing the deadline and failing to revalidate will result in suspension of your Medicare payments and eventually cause you to lose your Medicare billing privileges. Once your Medicare Provider Transaction Access Number (PTAN) has been deactivated, no claims will be paid retroactively. This means that any transport you provide to a Medicare beneficiary between the date that your organization’s PTAN is deactivate until the time your revalidation application is approved and you are re-credentialed cannot be paid by the MAC. Your organization loses reimbursement within that timeframe.